HomeMy WebLinkAbout03-5465IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIC C. WALSER,
Plaimiff
DANIELLE L. CHARETTE,
Defendant
)
)
)
)
)
)
)
NO.
CIVIL ACTION - LAW
CUSTODY/VISITATION
COMPLAINT FOR PARTIAL CUSTODY
AND NOW, comes Plaintiff, Eric C. Walser, by and through his counsel, Howett,
Kissinger & Conley, P.C., who hereby files the instant Complaint for Partial Custody and in
support thereof avers as follows:
1. Plaintiff is Eric C. Walser, an adult individual currently residing at 6512
Rising Sun Road, Philadelphia, Philadelphia County, Pennsylvania 19111.
2. Defendant is Danielle L. Charette, an adult individual currently residing at
90 West Lauer Lane, Camp Hill, Cumberland County, Pennsylvania 17011.
Plaintiff seeks partial custody of the following child:
Name
Chance Charette
Present Residence
90 West Lauer Lane
Camp Hill, PA
7 months (d.o.b. 3/11/03)
4. The child was bom out of wedlock and presently is in the custody of
Defendant at the above listed address. The child has resided with Defendant since her birth.
5. Defendant, who is single, is the mother of the child. She currently resides
with her mother, Millison Charette, and her stepfather, Ken Diehl.
6. Plaintiff, who is single, is the Father of the child. He currently resides with
his mother and father, Maureen and Gerhard Walser.
7. Plaintiff has not participated as a party or a witness, or in another capacity,
in other litigation concerning custody of the child in this or another court.
8. Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth or any other state.
9. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
10. The best interests and permanent welfare of the child will be served by
granting the relief requested because:
(a)
(b)
Sole custody isolates the child from a non-custodial parent;
It is in the best interests of the child that open and '
meaningful access be maintained with each parent so that she may have a relationship with each
parent;
(c) Since the child's birth, Plaintiffhas had regular and
frequent contact with the child and, as a result, the child has developed an emotional attachment
to him and the severing of that attachment is not in the child's best interests;
(d) Permitting each party to be involved in the life of the
child enables the child to share with each parent the intimate contact necessary to strengthen a
true parent child relationship;
(e) As part of Plaintiff's regular and frequent contact with the
child, he has assisted to attending to the basic needs of the child and, therefore, has the requisite
skills to properly parent an infant child; and
(f) Plaintiff seeks to expand upon the supervised visitation
Defendant has permitted to date to a more general and customary partial custody schedule
befitting a parent who desires to maintain involvement in a child's life. There is presently no
impediment to permitting Plaintiffto begin exercising periods of partial custody either on an
immediate basis or gradually over time.
11. Each parent whose parental rights of the child have not been terminated
and the parent who has physical custody of the child have been named as parties to this action.
WHEREFORE, Plaintiff respectfully requests the Court enter an order granting him
periods of partial custody of the subject child and awarding the parties shared legal custody.
/~/~/C) Respectfully submitted,
Date: /d) _~ ,-~ ..
Darren J.
HOWETT, KISS1NGER & CONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff, Eric C. Walser
VERIFICATION
I, Eric C. Walser, hereby swear and affirm that the facts contained in the foregoing
Complaint for Partial Custody are
tree and correct to the best of my knowledge, information and belief and are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Date: October 10, ~
Er/cC. Walser
ERIC C. WALSER
PLAINTIFF
V.
DANiELLE L. CHARETTE
DEFENDANT
IN 'I2HE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-5465 CIVIL ACTION LAW
IN CUSTODY
ORDER OFCOURT
AND NOW, Monday, October 20, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the concili
at 301 Market Street, Lemoyne, PA 17043 on Monday, November 24, 2003 at 8:30
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute;
if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a tempor~x
order. All children age five or older may also be present at the conference. Failure to appear at the conference ma
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours priior to scheduled hearing.
FOR THE COURT.
ttor,
M
By: /s/
Melissa P. Greevy. Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americar
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the schedul{
conference or hearing.
YOU SHOULD TAKE TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIC C. WALSER,
Plaintiff
DANIELLE L. CHARETTE,
Defendant
NO. 03 - 5465 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY/VISITATION
AFFIDAVIT OF SERVICE
Darren J. Hoist, being duly sworn according to law, deposes and says that he is an
attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on the
23ra day of October, 2003, he sent the original of the attached letter, with which was enclosed a
time-stamped copy of the Complaint for Partial Custody and Order scheduling the custody
conciliation in the above-captioned matter, properly endorsed, to the Defendant, Danielle L.
Charette, by certified mail, postage prepaid, return receipt requested, restricted delivery, pursuant
to Pa.R.C.P. 1930.4, to 90 West Lauer Lane, Camp Hill, PA, 17011, the Defendant's last known
address, and that the return receipt card which was signed by D. Charette, marked as having been
delivered to her on October 24, 2003, is attached hereto and made a part hereof.
Darren J. Hfflst, Esquire
HOWETT, KISSINGER & CONLEY, P.C.
130 Walnut Street
P. O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
SWORN TO AND SUBSCRIBED
be~xre me this 28th day of October, 2003.
N~TAmAL SEAL
~BRA M. ~HIM~, NOTARIr ImUBLJ~
MY COMMISSION ~1~$ A~ ~. 2005
JOHN C HO~ETT JR
DONALD T KISSING£R
CINDY S CONLEY
DARRENJ HOLST
DEBRAM SHIMP
Legal Assistant
HOWETT, KISSINGER & CONLEY, P.C.
130 WALNUT STREET
F'OST OFFICE BOX glO
October 23, 2003
FAX (717) 234-5402
CERTIFIED MAIL & REGULAR MAIL
RESTRICTED DELIVER Y
RE TURN RE CEIP T RE Q UES TED
M& Danielle L. Charette
90 West Laner Lane
Camp Hill, PA 17011
Re: Walser v. Charette
No. 03,5465
Dear Ms. Charette:
I write on behalf of Eric Walser, whom I represent in the above-referenced matter.
Enclosed, constituting proper service under the rules of civil procedure, please find a certified
true and correct copy ora Complaint for Partial Custody that our office filed with the Court of
Common Pleas of Cumberland County. Please note on the Order that a conciliation conference
has been scheduled for Monday, November 24, 2003 at 8:30 a.m. before Melissa P. Greevy,
Esquire.
Mr. Walser is generally pleased with the level of contact he has had with Chance over the
last seven months. Obviously, given the geographic distance, he has thus far not been able to
visit with Chance as much as he would like. Mr. Walser advises that you and he have been able
to communicate quite well concerning the scheduling of visitation. He is hopeful that you and he
will continue to communicate directly with each other concerning the health and welfare of
Chance.
To date, Mr. Walser has been afforded only periods &supervised visitation. The instant
action was initiated, not in an attem~0t to usurp from you primary physical custody, but rather to
facilitate the implementation ora normal and customary custodial schedule befitting a non-
custodial parent. Certainly, it behooves both parties to have a written order delineating periods
of custody so as to avoid any possibility &dispute, which often arises when custody is based
solely on an oral arrangement.
Danielle L. Charette
October 23, 2003
Page Two
Mr. Walser is confident, and it is my hope, that you and he will be able to work directly
with each other in arranging and implementing a schedule of partial custody. Mr. Walser desires
the ability to exercise periods of partial custody with Chance at his home as any other parent
might do. At this time, I see no impediment to the implementation of a partial custody schedule.
If you desire to retain counsel in this matter, I would ask that you please forward the
enclosed complaint and this cover letter to his or her attention, and your attorney can contact me
at his or her convenience. If you do not retain counsel, please feel free to contact me directly.
Either way, I would ask that you or your attorney get in touch with me in advance of the
scheduled conciliation. To the extent an agreement is possible, it is prudent to finalize an
agreement in advance of the conciliation so as to avoid the cost of attending the proceeding.
Thank you for attention to this matter. I look forward to speaking with either you or your
attorney in the very near future. I will reiterate that Mr. Walser initiated this action solely to
assist in the implementation of a partial custody schedule.
Sincerely,
Darren J. Hoist
DJH/glg
Enclosure
cc: Eric C. Walser (w/encl.)
,(
7003 1010 0002 8156 2792
ERIC C. WALSER,
Plaintiff
DANIELLE L. CHARETTE,
Defendant
DEC 2 2 2OO3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-5465 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
TEMPORARY ORDER OF COURT
AND NOW, this ~'~' day of December, 2003, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Le,qal Custody. The parents, Eric C. Walser and Danielle L. Charette, shall
have shared legal custody of the minor child, Chance Charette, born March 11, 2003. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the child's general well-being including, but not
limited to, all decisions regarding her health, education and religion. Pursuant to the terms
of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to
the child including, but not limited to, medical, dental, religious or school records, the
residence address of the child and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody of the child
subject to Father's rights of partial custody which shall be arranged as follows:
A. Effective December 27, 2003, on alternating weekends and on
either Saturday or Sunday, or both, from 9:00 a.m. to 5:00 p.m. These periods
of partial custody shall be exercised in the local area.
B. On weekends which would ordinarily be Mother's custodial
weekend, if Mother does not have pre-existing plans, Father may have a
period of partial custody for up to three (3) hours on either Saturday or Sunday
to be exercised in the local area.
C. Father will call Mother by Wednesday of each week to confirm
his weekend plans for exercise of partial custody.
D. Commencing February 6, 2004, on alternating weekends, from
Friday at 7:30 p.m. until Sunday at 6:30 p.m.
NO. 03-5465 CIVIL TERM
3. Transportation. The parties will share transportation in the following fashion:
A. Father will provide all transportation incident to custodial
exchanges which commence on Friday evenings and on all weekends during
which he exercises partial custody prior to February 6, 2004.
B. Effective February 8, 2004, at the conclusion of Father's periods
of partial custody, the parties will meet for the custodial exchange at the
Holiday Inn off of the Morgantown exit of the Pennsylvania Turnpike.
4. During any period of custody or visitation the parties to this Order shall not
possess or use controlled substances, neither shall they consume alcoholic beverages to
the point of intoxication. The parties shall likewise ensure, to the extent possible, that the
other household members and/or house guests comply with this prohibition.
5. Neither party will allow the child to be subject to second hand smoke.
6. Vacation. Each parent will be entitled to seven (7) consecutive days of
vacation to encompass their custodial weekend. The parties will provide each other with at
least thirty (30) days written notice of their intended vacation plans.
7. Holidays. The following holiday schedule shall take precedence over the
ordinary schedule.
A. Commencing with Easter 2004, the parties will alternate the
following holidays: Easter, Memorial Day, Independence Day, Labor Day and
Thanksgiving. The custodial period for these holidays shall commence the day
before the holiday and continue until the day after the holiday with the parents
working cooperatively to determine the beginning and ending points of these
custodial periods. In the event that a Monday holiday follows Father's custodial
weekend, Father's custody will be extended until Monday evening.
B. Christmas. Christmas 2003 shall be Mother's holiday.
NO. 03-5465 CIVIL TERM
8. The Custody Conciliation Conference shall reconvene on February 9,
2004 at 1:30 p.m. at the office of the Custody Conciliator, Melissa Peel Greevy,
Esquire, 301 Market Street, Lemoyne, PA 17043. It is contemplated at the time the
Custody Conciliation Conference reconvenes that the parties will discuss a sharing of the
Christmas holiday in subsequent years and Mother's potential plan for relocation.
Dist:
BY THE COURT:
DEC 2 2 2003
ERIC C. WALSER,
Plaintiff
DANIELLE L. CHARETTE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-5465 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Chance Charette March 11, ~003 Mother
2. A Custody Conciliation Conference was held on December 16, 2003 following
Father's October 15, 2003 Complaint for Partial Custody. Present for the conference were:
the Father, Eric L. Walser, and his counsel, Darren J. Hoist, Esquire; the Mother, Danielle L.
Charette, and her counsel, Diane M. Dils, Esquire.
3. The Parties reached an agreement in?he ~0r:of'~n Order as attached.
/ Date - ) ' y, quire
Custody Conciliator
:222263
; C. WALSER,
Plaintiff
V. :
:
DANIELLE L. CHARETTE,
Defendant
FEB 182004 ~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-5465 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
HESS, J. ---
TEMPORARY ORDER OF COURT
AND NOW, this ~-'~'~' day of February, 2004, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. ~. The parents, Eric C. Walser and Danielle L. Charette, shall
have shared legal custody of the minor child, Chance Charette, born March 11,2003. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the child's general well-being including, but not
limited to, all decisions regarding her health, education and religion. Pursuant to the terms
of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining
to the child including, but not limited to, medical, dental, religious or school records, the
residence address of the child and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. ~. Mother shall have primary physical custody of the child
subject to Father's rights of partial custody which shall be arranged as follows:
A. Commencing February 6, 2004, on alternating weekends, from
Friday at 7:00 p.m. until Sunday at 5:30 p.m.
B. On weekends which would ordinarily be Mother's custodial
weekend, if Mother does not have pre-existing plans, Father may have a
period of partial custody for up to three (3) hours on either Saturday or Sunday
to be exercised in the local area.
C. Father will call Mother by Wednesday of each week to confirm
his weekend plans for exercise of partial custody.
NO. 03-5465 CIVIL TERM
3. Transportation. The parties will share transportation in the following fashion:
A. Father will provide all transportation incident to custodial
exchanges which commence on Friday evenings and on all weekends during
which he exercises partial custody prior to February 6, 2004.
B. Effective February 8, 2004, at the conclusion of Father's periods
of partial custody, the parties will meet for the custodial exchange at the
Holiday Inn off of the Morgantown exit of the Pennsylvania Turnpike.
4. During any period of custody or visitation the parties to this Order shall not
possess or use controlled substances, neither shall they consume alcoholic beverages to
the point of intoxication. The parties shall likewise ensure, to the extent possible, that the
other household members and/or house guests comply with this prohibition.
5. Neither party will allow the child to be subject to second hand smoke.
6. Vacation. Each parent will be entitled to seven (7) consecutive days of
vacation to encompass their custodial weekend. The parties will provide each other with at
least thirty (30) days written notice of their intended vacation plans.
7. Holidays. The following holiday schedule shall take precedence over the
ordinary schedule.
A. Commencing with Father having custody for Easter 2004, the
parties will alternate the following holidays: Easter, Memorial Day,
Independence Day, Labor Day and Thanksgiving. The custodial period for
these holidays shall commence at noon the day before the holiday and continue
until noon the day after the holiday. In the event that a Monday holiday follows
Father's custodial weekend, Father's custody will be extended until Monday
evening.
B. Christmas. In even numbered years Father shall have custody for
Christmas commencing on December 25th at noon and continuing through
December 30th at 6:00 p.m. In odd numbered years, Father will have custody
for Christmas commencing at noon on December 26th and continuing through
December 30th at 6:00 p.m. In even numbered years, Mother will have custody
from December 24th at noon until December 25th at noon and in odd numbered
years, Mother will have custody from December 24th at noon until December
26th at noon.
NO. 03-5465 CIVIL TERM
8. A relocation hearing is scheduled in Courtroom Number 4 of,the Cumbe, rland
County Courthouse, on the /'~ day of ~(~.2~, ,2004, at /, ~30 o clock
/) .M., at which time testimony will be taken, leor the purposes of the hearing, the Mother,
Danielle L. Charette, shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for the parties or the parties pro se shall file with the Court and
opposing counsel/party a memorandum setting forth each party's position on relocation, a
list of witnesses who are expected to testify at the hearing, and a summary of the
anticipated testimony of each witness. These memoranda shall be filed at least ten days
prior to the hearing date.
Dist:
BY THE COURT:
hA. Hess, J.
,~arren J. Hoist, EsquJre, PO Box 810, Harrisburg, PA 17108
,./Diane M. Dils, Esquire, 1017 N. Front Street, Harrisburg, PA 17102
ERIC C. WALSER,
Plaintiff
DANIELLE L. CHARETTE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-5465 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
19'15.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME
Chance Charette
DATE OF BIRTH
March 11, 2003
CURRENTLY IN THE CUSTODY OF
Mother
2. The parties' second Custody Conciliation Con'terence was held on February 9,
2004, as had been planned at the December 16, 2003 Custody Conciliation. Present for the
conference were: the Father, Eric L. Walser, and his counsel, Darren J. Hoist, Esquire; the
Mother, Danielle L. Charette, and her counsel, Diane M. Dils, Esquire.
3. Two issues were planned to be addressed at the Conference: the sharing of
the Christmas holidays in 2004 and subsequent years and Mother's desire to relocate to
Hilton Head, South Carolina. Additionally, Mother expressed her desire to be relieved from
any responsibility in the sharing of transportation incident to the custodial exchanges under
the present Order. The parties were able to reach an agreement regarding the sharing of
the Christmas holidays, but not to the shadng of transportation or relocation. The only
Order issued in this case is dated December 29, 2003. That Order contains a transportation
provision to which the parties had previously agreed. The Conciliator makes no
recommendation to modify that prior to the time of hearing.. Prior to the February 9, 2004,
Custody Conciliation Conference, counsel had been discussing the possibility of resolving
the relocation issue by agreeing to delay the move until after the child was age two if Father
would agree to have the move happen after that time and if: a conciliation would occur prior
to the move to work out the details for Father's custodial schedule. Because that was the
framework within which the parties' discussions were proceeding and because no
agreement was reached to allow the relocation, Mother did not appear at the conference
prepared to discuss an alternative custodial schedule for Father, should the relocation
Occur.
NO. 03-5465 CIVIL TERM
4. The parties met in October, 2001, in Camp Hill, Pennsylvania. At that time,
Father lived in Camp Hill and Mother resided in New York City. Father subsequently
obtained employment and moved to Philadelphia, Pennsylvania, where he continues to
reside with his parents. Mother continued to live in New York City until Fall, 2002. She
experienced significant emotional distress after the events of September 11, 2001. After
she became pregnant with the parties' child in August, 2002, she quit her job in New York
and relocated to Camp Hill where she resided with her parents.
5. Mother's position on custody is as follows: Mother presently resides in a home
owned by her parents in Camp Hill, Pennsylvania. She works as a waitress in downtown
Harrisburg. Her mother and stepfather moved to Hilton Head, South Carolina in October,
2003. They are presently looking to pumhase a home, at which time they intend to sell the
home in which Mother resides. Mother would like to relocated to Hilton Head, South
Carolina as well. Although she does not have employment there now, she is confident of
her ability to obtain employment in that community because she had lived there for
approximately seven years. If she is permitted to relocate with the child, it is her plan to
obtain employment and go to school part time. She will likely reapply to the Savannah
School of Art and Design in Savannah, Georgia. She had attended this school previously.
This school is approximately twenty minutes from Hilton Head, South Carolina. Mother
reports that Father has always known of her desire to move back to South Carolina and they
had discussed the possibility of moving there together as a couple. Mother points to the
availability of support from her mother and stepfather if she is allowed to relocate with the
child.
6. Father's position on custody is as follows: Father is opposed to the relocation.
Of concern to Father is how the parties will be able to arrange the logistics of his continued
contact with the child if the relocation is permitted. He estimates the drive time to be
approximately ten to twelve hours. Neither party is of significant financial means at this
stage of their careers. Therefore, the expenses associated with the travel incident to
custodial exchanges necessarily impact the practicality of a modified custodial schedule.
Father points out that Mother could obtain employment at locations which would not be so
great a distance and which would allow her to finish art school. He believes that things are
progressing nicely with his establishment of a bond with the child, and does not want to
have a greater geographic distance interfere with that progress. He is concerned that the
relocation will decrease the frequency of the contact with this very young child and impair
the growth of that relationship. Should the Court permit the relocation, Father asks that the
Court revisit the issue of transportation incident to the custodial exchange at the time that it
determines the proper alternative custodial schedule for Father.
NO. 03-5465 CIVIL TERM
7. The parties have not reached an agreement regarding Mother's desired
relocation. Therefore, a hearing will be necessary. Counsel have waived objections to
discovery prior to time of hearing. Mother will submit a proposed alternate visitation
schedule to Father no later than March 17, 2004.
8. The parties agreed to slight modifications on the custodial weekend time and
more specific details regarding holiday sharing which are specified in Order attached hereto.
Date
Melissa Peel Greevy, Esquire
Custody Conciliator
:222263
ERIC C. WALSER,
Plaintiff
VS.
DANIELLE L. CHARETTE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 03-5465 Civil Term
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ,~q° day of ~'~,~-~ ,2004, this Court having been
informed that the Defendant, Danielle L. Charette, is not pursuing her request to relocate
with the minor child at this time, and further, this Court being advised that the parties are
in agreement with the Custody Order entered February 26, 2004, it is hereby Ordered that
the Relocation Hearing scheduled for April 19, 2004, is hereby cancelled and the
Temporary Order of Court dated February 26, 2004, is hereby made a Final Order of
Court and is incorporated herein.
BY THE COURT:
The H/grforable Kevin A. Hess
/
S.~rrtributi°n:
en J. Holst, Esquire, P.O. Box 810, Harrisburg, PA 1.7108
~I~iane M. Dils, Esquire, 1017 North Front Street, Harrisburg, PA 17102